Jones v. Williams

Under Religious Land Use and Institutionalized Persons Act, relief is not an unequivocal expression of state consent to private suits for monetary damages.

Clarence Jones, a devout Muslim, was a former inmate at the Oregon State Penitentiary. His religion prohibits him from consuming or handling pork. Jones filed suit against Oregon Department of Corrections (“the Department”), alleging the Department violated his free speech and free exercise constitutional rights when he was required to handle pork and when he ate a tamale pie for lunch, wherein no sign was displayed indicating that the tamale contained pork. Jones sought monetary damages and injunctive relief under 42 U.S.C. § 1983 and the Religious Land Use and Institutionalized Persons Act (“RLUIPA”). The district court granted the Department’s summary judgment. On appeal, the Ninth Circuit whether relief was appropriate. However, under RLUIPA, “appropriate relief” cannot be construed as a waiver of sovereign immunity. Thus, the panel held that Jones could not obtain monetary relief. Additionally, since Jones was already released from prison, injunctive relief was moot. Furthermore, the panel found that there was insufficient evidence as to whether a tamale pie actually contained pork and thus affirmed the summary judgment in part. Therefore, the panel affirmed the district court, in part. AFFIRMED in part and VACATED and REMANDED in part.